Registration for the December webinar has ended.
Please check back soon to register for our next webinar.
Divisive Corporate Reorganizations: Threading the Eye of the I.R.C. § 355 Needle
Tuesday, December 3 at 12pm (CST)
Speaker:
Stephen A. Beck, J.D., LL.M. and Board Certified in Tax Law by the TBLS.
About this Webinar
Overview
In general, the distribution of appreciated assets from a corporation results in income tax liability to both the distributing corporation and the distributee shareholders. I.R.C. § 355, however, provides an exception through which a corporation can divide and distribute appreciated assets without triggering income tax liability to either the corporation or the shareholders. But qualifying under I.R.C. § 355 can be very difficult – like threading the eye of a needle. This presentation discusses the many requirements that must be satisfied under I.R.C. § 355 to support deferral of taxable gain recognition, as well as potential pitfalls that could cause a divisive transaction to result in double taxation to the corporation and shareholder.
Key Topics
What non-tax business purposes qualify for Section 355 purposes?
What must a corporation’s activities involve to establish satisfaction of the active trade or business requirement?
To what extent may the resulting corporations own nonbusiness assets without causing the divisive transaction to constitute a “device to distribute earnings and profits,” thereby resulting in taxable gain recognition?
To what extent must the shareholders continue to own the resulting corporations following the divisive transaction, and for how long, to satisfy the “continuity of interest” requirement?
Details
Course Level: Intermediate
Prerequisite: Basic knowledge of Corporate income taxation
Cost: Free
CPE and MCLE Credit Info:
Course Number: 174260383
CPE Credit: 1.20 Hrs.
MCLE Credit: 1.00 Hr.
CFP Credit Info:
CFP Program ID: 331796
CFP Credit: 1.00 Hr.
About the Speaker
Stephen A. Beck, J.D., LL.M.
Partner
Mr. Beck is a Board Certified tax attorney who provides Federal income tax and Texas franchise and sales tax advice to businesses of all types and sizes, including Subchapter C corporations, Subchapter S corporations, partnerships, limited liability companies, and entities disregarded for Federal income tax purposes. He advises on tax issues arising during all phases of business operations, including formation, restructuring of ownership interests, acquisitions, dispositions, mergers, consolidations, liquidations, international transactions, issuance of deferred and equity compensation, and business succession planning. He represents businesses and entrepreneurs in a broad range of industries, including professional services, manufacturing, technology, oil and gas, and real estate. He also advises tax-exempt organizations under Section 501 of the Internal Revenue Code.
Mr. Beck also represents individuals, businesses, and estates in tax related controversy matters, including Internal Revenue Service audits, appeals, and litigation in Federal courts, including the U.S. Tax Court and Fifth Circuit Court of Appeals. He also represents taxpayers in franchise and sales tax disputes with the Texas Comptroller of Public Accounts.
Mr. Beck is Board Certified in Tax Law by the Texas Board of Legal Specialization. He has served as an adjunct law professor at Southern Methodist University Dedman School of Law, where he taught Corporate Income Taxation. He has also served as the Chairperson of the Dallas Bar Association’s Peer Assistance Committee and Co-Chair of the Texas Bar Tax Section Partnership and Real Estate Committee. Mr. Beck was admitted to practice in Texas in 1998 and the District of Columbia in 2000.
Read his full bio here. You can contact Mr. Beck at 214-744-3700 or by email at sbeck@meadowscollier.com.
About Meadows Collier
At Meadows Collier, we are dedicated to supporting continuing education of Dallas tax professionals including CPA’s, CFPs, and legal experts. We offer free monthly webinars and presentations that provide CPE, MCLE, and CFP credits where applicable. Most firm lawyers hold an LL.M. in Taxation and/or are Board Certified in Tax Law by the Texas Board of Legal Specialization. These free webinars cover a wide array of topics relevant to CPAs, business leaders, legal professionals, and tax specialists. Our webinar topics include federal and state tax updates, IRS enforcement and initiatives, estate planning, corporate tax issues, tax controversy and litigation, and more. Stay informed about the latest developments and gain valuable knowledge from industry leaders. Sign up today to enhance your expertise and navigate the evolving economic landscape with confidence. Dallas tax professionals can rely on Meadows Collier for high quality continuing education.
Founded in 1983, Meadows Collier is a nationally recognized law firm based in Dallas, Texas, specializing in all areas of taxation. Our expertise spans a wide range of complex tax and business matters, including federal and state tax issues, white-collar criminal defense, government regulatory defense, cryptocurrency and digital asset management, wealth planning, corporate law, real estate transactions, and other commercial legal needs. We represent both businesses and individuals in high-stakes litigation, providing solutions for the most challenging tax situations. Dallas tax professionals trust Meadows Collier for comprehensive legal support and expert tax solutions.